data management for the new and expected baseline … · sampling apparently not required ......
TRANSCRIPT
Data Management for the New and Expected Baseline Sampling Rules
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Dr. David W. [email protected]
San Antonio, TXNovember 14, 201320th IPEC Conference
Introduction
Petroleum project challengesPetroleum data challengesTypes of petroleum environmental dataBaseline sampling
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Baseline samplingExample state sampling rulesColorado Rules 609 and 318AFuture direction and discussion
Petroleum Project Challenges
Baseline samples should be taken prior to and after drillingAccidental spills during drilling may require sampl ing and analysisHydraulic fracturing is now under great scrutiny fr om a number of angles: water supply, fluid composition, and dispos al or re-use of frac fluidsUnconventional resources such as coalbed and shale gases often
Petroleum environmental projects from upstream to downstream have different needs:
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Unconventional resources such as coalbed and shale gases often involve the production of a large amount of water, which must be managed, and often discharge monitoring reports mus t be provided to regulatorsTransportation activities, such as by pipeline and truck, can result in spills with environmental impactRefining has its own set of environmental issues, s uch as monitoring of discharges and nearby groundwater and surface water
Petroleum Data Challenges
Handling on non-detected resultsMultiple dilutions to maintain a linear instrument responseComparison to multiple, and often complex, regulatory limits and target levels
Petroleum environmental data provides special challenges:
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regulatory limits and target levelsSpecial handling of non-aqueous phase liquid dataPotentially large amounts of dataInconsistent reporting of hydrocarbon rangesOften complex site geology
Baseline Sampling
Program requirement TypesVoluntary - Example: COGAMandatory - Examples: COGCC, Ohio
TimingPre-drillingPost -drilling
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Post -drillingReporting requirements
AgencyOperatorLandowner
Example State Sampling RulesState Agency Summary of Rules Reference
Alabama State Oil and Gas Board of Al Sampling apparently not required 1 gsa.state.al.us/documents/misc_ogb/goldbook.pdf
Alaska Alaska Oil and Gas Conservation Commission
Sampling apparently not required www.legis.state.ak.us/cgi-bin/folioisa.dll/stattx07/query =%5BJUMP:'AS3105030'%5D/doc/%7B@1%7D?firsthit
Arkansas Arkansas Oil and Gas Comm. Sampling apparently not required aogc.state.ar.us/operator_requirements.htm
California Division of Oil, Gas and Geothermal Resources
May be required by state supervisor ftp://ftp.consrv.ca.gov/pub/oil/laws/PRC01.pdf
Colorado Colorado Oil and Gas Conservation Commission
Baseline sampling before and after drilling 2 cogcc.state.co.us/RR_HF2012/Groundwater/FinalRules/FinalRule609-01092013.pdf
Kansas Kansas Geological Survey Baseline sampling voluntary www.kcc.state.ks.us/conservation/kgs_baseline_groundwater_quality.pdf
Louisiana Louisiana Dept. of Nat. Res. Sampling apparently not required dnr.louisiana.gov/assets/OC/43XIX_June2010.pdf
Ohio Ohio Dept. of Natural Resources Baseline sampling before drilling 2 oilandgas.ohiodnr.gov/laws-regulations/senate-bill-315
Oklahoma Oklahoma Corp. Commission Baseline sampling recommended oklahomawatersurvey.org/?p=214
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Pennsylvania Pennsylvania Dept. of Environmental Protection
No sampling requirement, but operators presumed responsible for pollution
stateimpact.npr.org/pennsylvania/tag/impact-fee/
New Mexico New Mexico Energy, Minerals and Natural Resources Dept.
Sampling apparently not required www.emnrd.state.nm.us/OCD/documents/SearchablePDFofOCDTitle19Chapter15created3-2-2012.pdf
New York New York State Dept. of Environmental Conservation
Baseline sampling before drilling proposed, voluntary sampling in southern New York
www.dec.ny.gov/energy/47554.html
North Dakota North Dakota Industrial Comm. Sampling not required www.dmr.nd.gov/oilgas/rules/rulebook.pdf
Texas Railroad Commission of Texas Sampling apparently not required, except City of Fort Worth
info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=16&pt=1&ch=3&rl=Y
Utah UT Div. of Oil, Gas and Mining Sampling apparently not required www.rules.utah.gov/publicat/code/r649/r649-003.htm
West Virginia West Virginia Department of Environmental Protection
No sampling requirement, but operators presumed responsible for pollution
www.legis.state.wv.us/WVcode/ChapterEntire.cfm?chap=22&art=6A§ion=18
Wyoming Wyoming Oil and Gas Conservation Commission
Pre-drilling sampling recommended 1 wogcc.state.wy.us/
1 Working with Ground Water Protection Council 2 Worked with GWPC
COGCC Rule 609
Rule 609, and modifications to Rule 318A, were published by the Colorado Oil and Gas Conserv ation Commission (COGCC) in February, 2013, for permits issued after May 1, 2013 These rules make Colorado the first state in the co untry These rules make Colorado the first state in the co untry to require pre- and post-drilling sampling of water sources near new oil and gas wells Consultants, labs, and software vendors have cooperated with COGCC to update the transfer of dat a to COGCC’s database using COGCC’s new XML or an Excel format
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Rule 609 Sample Requirements
Sampling required for new oil and gas wells, multi- site wells, and dedicated injection wellsInstalling of monitoring wells is not requiredSamples must be collected from up to four water sources within a half mile of proposed well locatio nOne pre-drill sample required with 12 months prior to setting conductor pipe
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setting conductor pipeTwo post-drill samples required, one 6-12 months an d one 5-6 years after drillingData must be made publicly available on the COGCC websiteRule 318A (Wattenberg Area) has slightly different requirements (one sample per quarter, one post-dril l)
Baseline Sampling and Reporting Steps
Determine locationsObtain landowner permissionTake samples and field measurementsEnter locations in COGCC websiteObtain the Facility IDImport field measurements
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Import field measurementsObtain and import lab dataReview dataExport to COGCC format, with Facility IDUpload to the COGCC websiteReview submission online
COGCC Facility Information
The first step on the state website is to upload the locationThe location is then given a Facility IDThis should be recorded and added to the lab and field data before upload
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the lab and field data before uploadThis can also be used on the COGCC website to retrieve and view the data
Typical Sample Location
Typical compliance costs:Sampling: $2,500Lab analysis: $500 - 600Isotopic analysis, if needed: $300 - 400 more
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Photo courtesy of Ben Baugh
Olsson Associates
needed: $300 - 400 more
Container Labels
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Planning the sample event
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Gathering Field Data
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Required AnalysesRequired Analyses for Rules 318A and 609 pre-drilli ng samples
pH Specific Conductance Total Dissolved Solids*Dissolved Gases (methane, ethane, propane)*Total Alkalinity as CaCO3*Bicarbonate Alkalinity as CaCO3* Carbonate Alkalinity as CaCO3*Major Anions (bromide*, chloride*, fluoride*, sulfate*, nitrate, nitrite as N, phosphorus)Major Cations (calcium*, iron, magnesium*, manganese, potassium*, sodium*)Other Elements (barium, boron, selenium, strontium) Bacteria (iron related, sulfate reducing, slime, coliform)
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Bacteria (iron related, sulfate reducing, slime, coliform) Total Petroleum Hydrocarbons*BTEX (benzene, toluene, ethylbenzene, xylenes)*Field Observations (odor, water color, sediment, bubbles, effervescence) Gas Composition (if methane exceeds 1mg/L) Stable Isotopes of methane and water (if methane exceeds 1 mg/L) Notes: 1. All of the above analyses must be performed on pre-drilling samples. Analyses marked with an asterisk (*) are also required for post-drilling samples. 2. If free gas or a dissolved methane concentration greater than 1.0 milligram per liter (mg/l) is detected in a water sample, gas compositional analysis and stable isotope analysis of the methane (carbon and hydrogen – 12C, 13C, 1H and 2H) must also be performed to determine gas type.3. Field observations such as odor, water color, sediment, bubbles, and effervescence must also be documented.
Example Laboratory Deliverable
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Importing Data
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Quality Control - Completeness
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Excel Table for Review
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Introduction
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Selection and Output
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Exporting COGCC Format
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Data files courtesy of Arthur Koepsell, COGCC
Uploading to COGCC
Data is uploaded using COGCC website
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Image courtesy of Arthur Koepsell, COGCC
Map from COGCC website
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Data from COGCC website
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Future Direction and Discussion
For COGCC, perhaps a way to download the Facility IDs and Sample IDsMore data retrieval options from websiteExpansion to other statesUse by the public
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Use by the publicUse in litigationOther issues?
Data Management for the New and Expected Baseline Sampling Rules
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Dr. David W. [email protected]
San Antonio, TXNovember 14, 201320th IPEC Conference